CORRESPONDENCE - 75E (GENERAL COMMENTS)

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Page 15; [1] Commented [DHS8j Dale Helvig 1/7/7 9 3:0'4:00 PM Park Santiago is a Historical resource and it should be treated as such. Under CELLA Guidelines Section 15064.5(a), the term "historical resources" includes the following: 1) A resource listed in, or determined to be eligible by the State Historical Resources Commission, for listing in the California Register of Historical Resources (Public Resources Code, Section 5024.1). 2) A resource included in a local register of historical resources, as defined in Section 5020.1(k) of the Public Resources Code or identified as significant in a historical resource survey meeting the requirements of Section 5024.1(g) of the Public Resources Code, will be presumed to be historically or culturally significant. Public agencies must treat any such resource as significant unless the preponderance of evidence demonstrates that it is not historically or culturally significant. The EIR response to this is: "This policy [Urban Design Element Policy 2.4 j is not relevant to the proposed project. As described in Section 4.4, Cultural/Historic Resources, Park Santiago is not identified by the General Plan or other City designation as a historic district." However, the General Plan Urban Design Element [page 11] identifies Park Santiago and Riverview West as examples of similar design districts. The General Plan Housing Element [page 56] goes on to talk about Historic Neighborhood Preservation. It states "Santa Ana has residential, commercial, and industrial areas that have cultural or historic significance to the community. Residential neighborhoods include, but are not limited to, French Park, Floral Park, Wilshire Square, Eastside, Washington Square, and Heninger Park residential neighborhoods. The City is also known for its historic Mexican barrios, including the Logan, Lacy, Delhi, and Santa Anita neighborhoods, which date to the late 1880s. Several of these are recognized as historical districts, while others are not. In addition to preservation strategies for individual structures, the City could explore strategies to identify and preserve neighborhoods or elements thereof that are locally considered worthy of preservation efforts, but not necessarily individually eligible for a formal state at, national historic designation." Page IS: [2) Commented [DH61 j Dale Helvig 1/7/20'19 3.54:00 PM An example from the Traffic Analysis in regards of the access at the 22 Freeway: "With the addition of project traffic, the intersection would continue to operate at an unsatisfactory LOS E in the a.m. peak hour and LOS F in the p.m. peak hour. Therefore, and the proposed project would not result in exceedance of the Caltrans criteria, and no impacts at other intersections would occur. Thus, impacts to intersections in the existing plus project with Option A would be less than significant. It's bad, it will stay bad, so it's OK. Amazingl EIR response: "Because the project would result in limited peak hour trips, it would not result in a change to the existing MOE [Measure of Effectiveness]". Page 19: [3] Commented[DH74] Dale Helvig 1/8/201911k AM What is missing is the Main Place Transformation Project. The City has restricted the scope of the r2525 EIR to development applications that were submitted, approved and/or under construction at or prior to the release of the NOP. CEQA 15130. DISCUSSION OF CUMULATIVE IMPACTS requires either a list of past, present, and probable future projects producing related or cumulative impacts, including, if necessary, those projects outside the control of the agency, or A summary of projections contained in an adopted local, regional or statewide plan, or related planning document, that describes or evaluates conditions contributing to the cumulative effect. The Main Place EIR was approved in the 1990's and is a known project. The fact that the new owner submitted a plan in May 2018 is irrelevant. The Main Place EIR did not evaluate the 2525 N. Main Residential Development. And the 2525 N. Main Residential Development EIR did not evaluate the Main Place. How is this looking at cumulative effects?